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Amazon.com Inc. v. FBA Stores, LLC

United States District Court, W.D. Washington

March 7, 2018

AMAZON.COM, INC., a Delaware corporation, AMAZON TECHNOLOGIES, INC., a Nevada corporation; and AMAZON SERVICES, LLC, a Nevada limited liability company, Plaintiffs,
v.
FBA STORES, LLC, a limited liability company; FBA DISTRIBUTORS, LLC, a limited liability company; FBA ADVANTAGE, LLC, a limited liability company; AWS, LLC, a limited liability company; ONLINE AUCTION LEARNING CENTER, INC., a corporation; CHRISTOPHER BOWSER, an individual; ADAM BOWSER, an individual; and DOE Companies 1-20, Defendants.

          Philip S. McCune, WSBA #21081 Christopher T. Wion, WSBA #33207 Attorneys for Plaintiffs

          Bradley S. Keller Keith D. Petrak Byrnes Keller Cromwell LLP Attorneys for Defendants

          Charles J. Rogers Conley Rose, P.C. Attorneys for Defendants

          Darlene F. Ghavimi Conley Rose, P.C. Attorneys for Defendants

          STIPULATED PROTECTIVE ORDER

          THE HONORABLE ROBERT S. LASNIK UNITED STATES DISTRICT COURT JUDGE

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection may be warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The parties acknowledge that this agreement is consistent with LCR 26(c). It does not confer blanket protection on all disclosures or responses to discovery, the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles, and it does not presumptively entitle parties to file confidential information under seal.

         2. "CONFIDENTIAL" AND "ATTORNEYS EYES ONLY" MATERIAL

         2.1 CONFIDENTIAL MATERIAL

         "Confidential Material" shall include documents and tangible things produced or otherwise exchanged that contain confidential or proprietary information of a Party or a Third Party to whom the Party reasonably believes it owes an obligation of confidentiality with respect to such document. Examples of Confidential Material include:

• Customer-identifying information or other confidential personal information, such as social security numbers, home addresses, or telephone numbers;
• Business and marketing plans;
• Personnel files;
• Personal information that is protected by law;
• Non-public financial information, such as non-public financial statements;
• Non-public pricing information;
• Trade secrets;
• Other confidential and proprietary information not publicly known.

         2.2 ATTORNEY'S ...


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